PRIVACY POLICY
This privacy notice explains what to expect when we collect and process your personal information in accordance with the UK GDPR (and the EU General Data Protection Regulation (GDPR).
DEFINITIONS
a) ‘Account data’ is data gathered directly from you or your employer for the purposes of entering into a contract for the services we offer
b) ‘Correspondence data’ is data gathered from you during our correspondence with you either directly or through our website
c) ‘Enquiry data’ is data contained in any enquiry you submit to us for the purposes of offering, marketing, and / or selling our services to you
d) ‘Mailing list data’ is data supplied by mailing list supplier companies for the purposes of marketing our services to you
e) ‘Notification data’ is data gathered directly from you for the purposes of subscription to our email updates and / or newsletters
f) ‘Profile data’ is data provided by you and held on our website for the purposes of entering into or the performance of a contract with us
g) ‘Publication data’ is data supplied directly by you and may be processed to help us in the administration of our website and /or the provision of our services
h) ‘Service data’ is data gathered directly from you or your employer during the provision of our services for the purposes of performing our side of a contract with you
i) ‘Transaction data’ is data produced during our supply of services to you and the keeping of correct records of these transactions
j) ‘Usage data’ is data gathered through our analytics tracking system about your use of our website
1. INTRODUCTION
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy, we explain how we will handle your personal data.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://churchhouseconf.co.uk/privacy-policy.
2. CREDIT
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com)
3. HOW WE USE YOUR PERSONAL DATA
3.1 In Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing;
(e) that all data is password protected and therefore stored securely
3.2 We may process your client account data (“account data“) The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.3 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.4 We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent or our legitimate business interest.
3.5 We may process your personal data (“mailing list data”) as supplied to us by mailing list companies. This data may include your name, address, telephone number, email address, gender, job title and employer. This data may be processed for the purposes of marketing our services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our business.
3.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and / or legitimate business interest.
3.7 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.8 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
3.9 We may process your personal data that are provided during the use of our services (“service data“). The service data may include your name, address, telephone number, email address, gender, job title and employer. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your bank details, card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our business.
3.11 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.12 We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. PROVIDING YOUR PERSONAL DATA TO OTHERS
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
4.2 We may disclose your service data to our suppliers or subcontractors insofar as reasonably necessary for the provision of services to you.
4.3 We may disclose your service data to our online service monitoring company (BDRC International) for the purposes of obtaining feedback on the standard of our service provision if you have indicated on the contract that you consent to be contacted in this regard.
4.4 Financial transactions relating to our website and services are handled by our Accounts Department. We will share transaction data with our Accounts Department only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to your relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. RETAINING AND DELETING PERSONAL DATA
5.1 Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain and delete your personal data as follows:
(a) Account data will be retained for seven years following the date of the last contact, at the end of which period it will be deleted from our systems.
(b) Enquiry data will be retained for five years following the date of the last contact, at the end of which period it will be deleted from our systems.
(c) Mailing list data will be retained either for the length of time agreed in the contract with the supplier of the mailing list or for a maximum of two years following the date of the last contact.
(d) Notification data will be retained for two years following the date of the last contact.
(e) Service data will be retained for seven years following the date of initial contact, at the end of which period it will be deleted from our systems.
(f) Transaction data will be retained for seven years following the date of the provision of services/event, at the end of which period it will be deleted from our systems.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of account data will be determined based on our legitimate interests namely the proper administration of our business.
5.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. AMENDMENTS
6.1 We may update this policy from time to time by publishing a new version on our website.
7. YOUR RIGHTS
7.1 In Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; or for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the UK or in any EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.12 You may exercise any of your rights in relation to your personal data by written notice/email to us, in addition to the other methods specified in this Section 8.
8. COOKIES THAT WE USE
8.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website
(b) status – we use cookies to help us to determine if you are logged into our website
(c) analysis – we use cookies to help us to analyse the use and performance of our website and services
9. COOKIES USED BY OUR SERVICE PROVIDERS
9.1 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
10. OUR DETAILS
10.1 We own our website and 1Minus1 are the website operators.
10.2 We are registered in England and Wales under registration number 02869220, and our registered office is at Church House, 27 Great Smith Street, London, SW1P 3AZ.
10.3 Our principal place of business is at Church House Westminster, Dean’s Yard, Westminster, SW1P 3NZ.
10.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form or live chat;
(c) by telephone, on 020 7390 1590; or
(d) by email, using sales@www.churchhouseconf.co.uk